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W3C Web Accessibility Initiative Statement on Web Access Report from UK Disability Rights Commission

From: Judy Brewer <jbrewer@w3.org>
Date: Wed, 14 Apr 2004 01:37:51 -0400
Message-Id: <5.1.0.14.2.20040414010738.03f47c00@localhost>
To: (Recipient list suppressed)

[The following statement is available on the W3C/WAI Web site:
http://www.w3.org/2004/04/wai-drc-statement.html ]

W3C WEB ACCESSIBILITY INITIATIVE STATEMENT ON WEB ACCESS REPORT FROM UK 
DISABILITY RIGHTS COMMISSION

The World Wide Web Consortium (W3C) offers the following comments as an 
initial response to the Web Access Report released 14 April 2004 by the UK 
Disabilities Rights Commission. The DRC Report explores the state of Web 
site accessibility and usability in the UK, and in some sections makes 
recommendations regarding work done by W3C's Web Accessibility Initiative 
(WAI).

W3C/WAI produces a set of three accessibility guidelines recognized as 
international standards. The WAI Guidelines -- a complementary set 
comprised of the Web Content Accessibility Guidelines 1.0, the User Agent 
Accessibility Guidelines 1.0, and the Authoring Tool Accessibility 
Guidelines 1.0 -- address requirements for making Web sites, browsers, 
media players, assistive technologies, and Web authoring tools accessible 
for people with disabilities. These WAI Guidelines have been developed with 
the international cooperation of industry, disability organizations, 
accessibility researchers, and government representatives. W3C/WAI is 
currently developing advanced versions of the WAI Guidelines.

The DRC Report focuses on issues experienced by disabled Web users, and 
makes a number of recommendations with regard to policy options in the UK, 
recommendations which may contribute to improved Web accessibility in the 
UK. W3C was not involved in any of the research or in the development of 
findings from the Report.

While W3C/WAI finds the report informative and the policy recommendations 
useful for addressing practical implementation issues within organizations, 
we comment here on some of the DRC Report findings, in order to address 
potential misunderstandings about W3C's WAI Guidelines introduced by 
certain interpretations of the data.

THE WAI GUIDELINES ADDRESS 95% OF BARRIERS REPORTED BY PEOPLE WITH 
DISABILITIES IN THE REPORT

Finding 5 of the DRC Report states:

"Nearly half (45%) of the problems experienced by disabled users when 
attempting to navigate websites cannot be attributed to explicit violations 
of the Web Accessibility Initiative Checkpoints. Although some of these 
reflect shortcomings in the assistive technology used, most reflect the 
limitations of the Checkpoints themselves as a comprehensive interpretation 
of the intent of the Guidelines...."

To the contrary, W3C/WAI's examination of the DRC data available as of 14 
April 2004 shows that 95% of the barriers reported are indeed covered by 
existing checkpoints in WAI Guidelines. Of the high-frequency problems 
identified in Table 5 of the DRC Report, 77% are covered by checkpoints of 
the Web Content Accessibility Guidelines 1.0, while 18% are covered by 
checkpoints of the User Agent Accessibility Guidelines 1.0. Essentially, 
the interpretation of the data in the report fails to account for the role 
of browser and media player accessibility, and the role of interoperability 
with assistive technologies, in ensuring that people with disabilities can 
use Web sites effectively.

A more complete picture of the interaction of Web site and browser 
accessibility might result in additional policy recommendations -- for 
instance, recommending that conformance to the User Agent Accessibility 
Guidelines be considered when selecting browsers, media players and 
assistive technologies. For instance FINDING 3 notes that many people with 
disabilities are unaware of the accessibility features in browsers; the 
User Agent Accessibility Guidelines address this issue by requiring that 
browsers and media players provide documentation of accessibility features 
to help users find and learn how to use features that they need.

Likewise, authoring tools conforming to Authoring Tool Accessibility 
Guidelines 1.0 play a complementary role in achieving accessibility by 
providing built-in support for production of accessible Web sites. 
Selection of improved authoring tools -- in combination with the awareness 
and training recommended in the DRC Report -- would likely result in a 
rapid increase in the number of accessible Web sites in the UK.

ACCESSIBILITY GUIDELINES ADDRESS BARRIERS SPECIFIC TO PEOPLE WITH 
DISABILITIES; USABILITY AFFECTS ALL WEB USERS

Accessibility of Web sites cannot be evaluated via automated evaluation 
alone, as noted in W3C/WAI's Evaluating Web Sites for Accessibility which 
recommends using a combination of different evaluation tools, manual 
evaluation by experts, and user-testing of accessibility features.

The user-testing methodology employed in this study revealed similar 
usability problems for disabled and non-disabled users alike, over and 
above the accessibility problems which created specific barriers for people 
with disabilities. Given the extremely small number of Web sites conforming 
to the Web Content Accessibility Guidelines in this study, however, it is 
hard to draw clear conclusions on the relationship between accessibility 
and usability measures.

Regardless, some data in the report support the conclusion that increased 
conformance to the Web Content Accessibility Guidelines 1.0 results in 
barrier reduction -- and therefore increased accessibility -- for people 
with disabilities. For instance, when comparing task-completion, 
accessibility has a disproportionate impact on disabled vs non-disabled users:

"On the sites with high accessibility, both groups successfully completed 
nearly all their tasks. However, on sites with low accessibility, 
non-disabled users still completed all their tasks, whilst blind users 
completed only 67%...."

W3C/WAI WELCOMES INPUT INTO WEB CONTENT ACCESSIBILITY GUIDELINES 2.0

W3C/WAI relies on feedback from all parts of the Web community as it 
develops the WAI Guidelines, and will consider the suggestions in Appendix 
2 of the DRC Report along with other input received while developing WCAG 
2.0. All feedback is evaluated for issues such as direct relevance to 
accessibility; how precisely such requirements can be tested; and relative 
priority with other accessibility requirements.

The most recent Working Draft of the Web Content Accessibility Guidelines 
2.0 is available, and information on where to send comments is available in 
the Status section of the document.

INFORMATION ABOUT W3C AND WAI

The World Wide Web Consortium (W3C) is an international forum which 
develops interoperable technologies (specifications, guidelines, software, 
and tools) to lead the Web to its full potential.

W3C's Web Accessibility Initiative (WAI) addresses accessibility of the Web 
for people with disabilities, through a variety of activities, including 
technical and guidelines development and educational work, including the 
WAI-TIES Project, funded by the EC Information Society Technologies 
Programme to increase training and implementation support on Web 
accessibility in Europe.


-- 
Judy Brewer    +1.617.258.9741    http://www.w3.org/WAI
Director, Web Accessibility Initiative (WAI), World Wide Web Consortium (W3C)
MIT/CSAIL Building 32-G530
32 Vassar Street
Cambridge, MA,  02139,  USA
Received on Wednesday, 14 April 2004 02:13:36 UTC

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